The Vodafone Code of · PDF file in which we operate. The Vodafone Business Principles set out...
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The Vodafone Code of Conduct The Vodafone Code of Conduct sets out Vodafone’s Business Principles together with guidance to explain how they apply in practice to every Vodafone employee
All our models are The Vodafone Way Heroes. They are:
Ivan Lastra Santamarina, Spain Teresa Bujalance Rodriquez, Spain Luis Jimenez Tunon, Spain Tamer Atef, Egypt Enrique Sanz Zazo, Spain Enrique David Fernandez Sanz. Spain Theodosis Gialamas (centre), Greece Helen Edwards (left), UK Begona Ibarreche Solaguren, Spain Remember that all policies referred to in this document can be found on the Company page of our intranet.
A message from our Chief Executive 5
Business Principles 6
Compliance with the law 8 Competition laws 8 Insider trading 9 Anti-bribery laws 9
Financial integrity 10 Financial integrity 10 Accurate and complete financial records 11 Contracts 11 Social and environmental considerations 11 Company assets 12
Public policy 13
Communications 14 Communications 14 Confidential information 15
Customers 16 Privacy 16
Employees 17 Equal opportunity 17 Harassment and bullying 18 Alcohol and drugs 19 Privacy 19
Communities and society 21
Health and safety 22
Individual conduct 23 Avoiding conflicts of interest 23 Gifts, entertainment and payments 24 Personal investments 24 Outside employment and board memberships 25 Friends, relatives and co-worker relationships 26
Duty to report 27
“ As an international company, we must ensure that we have the trust and respect of each and every local community in which we operate. ”
A message from our Chief Executive
Vittorio Colao Vodafone Chief Executive Officer
As an international company, we must ensure that we have the trust and respect of each and every local community in which we operate. The Vodafone Business Principles set out our ethical standards to ensure we achieve this, and this Code of Conduct explains what these Business Principles are and how they apply in practice to every Vodafone employee. We all need to apply them to ensure we are also admired for having the highest standards of integrity.
Personally, I am passionate about working for a company that upholds such principles and ensures trust, both internally and externally, to achieve admiration by our customers, shareholders and employees.
Business Principles Compliance with the law We will comply with the provisions of all applicable domestic and international
laws and appropriate standards and principles.
Financial integrity We will provide the best possible return for our shareholders over the longer term. We will base our investment decisions, acquisitions and business relationships on economic criteria but will also take into account social and environmental considerations.
Public policy We will voice our opinions on government proposals and other matters that may affect Vodafone and our stakeholders. We will not make gifts or donations to political parties or intervene in party political matters.
Communications We will communicate openly and transparently with all our stakeholders within the bounds of commercial confidentiality. We will protect confidential information from improper disclosure, and any authorised communication of confidential information should be limited to individuals who need it to carry out their work.
Customers We will value the trust our customers place in us and will safeguard the information provided to us.
Employees We will base relationships with and between employees on respect for individuals and their human rights and will not tolerate child labour. We will not accept any form of discrimination, harassment or bullying. We will pursue equality of opportunity and inclusion for all employees through our employment policies and practices.
Environment We will commit to protecting the environment. We will minimise our use of finite resources (such as energy, water and raw materials) and the release of harmful emissions to the environment (including waste, air emissions and discharges to water). We will seek to improve the environmental performance of the products and services we provide, as well as support those that offer environmental and social benefits to our customers.
Communities and society We will engage with local communities to help us understand and respond to any concerns they may have, for example in relation to network deployment. We will always provide our stakeholders with access to correct, relevant and current information and build trust through integrity, transparency, honesty and objectivity. We will invest in society in a way that makes effective use of our resources, including support for charitable organisations.
Health and safety We will protect the health, safety and wellbeing of our customers, employees, partners and the communities in which we operate and disclose any information that comes to our knowledge that clearly demonstrates that any of our products or services breach internationally accepted safety standards or guidelines.
Individual conduct We will act with honesty, integrity and fairness in our dealings both internally and externally. We will not tolerate any form of bribery, including improper offers of payments or gifts to or from employees. We will avoid any contracts that might lead to, or suggest, a conflict of interest between personal activities and the business. We will neither give nor accept hospitality or gifts that might appear to incur an obligation. We will pursue mutually beneficial relationships and seek to promote the application of our Business Principles with our business partners and suppliers.
Competition laws As a customer-obsessed company, Vodafone has a strict policy that it will not engage in anti-competitive practices.
Most countries have laws designed to protect free and fair competition. These laws prohibit arrangements with competitors that restrain trade, such as price fixing, allocating customers or abuse of a dominant position. The laws may apply both to Vodafone and to organisations that we work with.
Although the spirit of these laws is straightforward, their application to particular situations can be quite complex. To ensure that Vodafone complies fully with these laws and that we can identify any breach of the laws outside Vodafone, each of us should have a basic knowledge of how they apply to our work.
In particular, agreements between competitors often give rise to competition law concerns. An ‘agreement’ can include an understanding or even an intention to do something and can be concluded by something as simple as a phone call. It may not be obvious who is a competitor and there may be instances where our suppliers, customers and business partners may be in competition with us.
Typical examples of anti-competitive behaviour include:
• Sharing of competitively sensitive information (eg prices, costs or sales volumes) with competitors.
• Entering into agreements with competitors to fix the price of products or services, including discounts, rebates or commissions.
• Entering into agreements not to compete with competitors for certain accounts or regions or agreeing market shares.
• Agreements with resellers to fix the minimum resale price of products or services.
This is not an exhaustive list and if you have any concerns about situations that may give rise to competition law issues, you should immediately contact your local Legal Department.
More information A competition law training module has been constructed by our legal team and is accessible online by clicking here.
All employees in competition sensitive positions are required to complete the training and all others are encouraged to complete the training. Further information on competition law, contacts and guidelines can be found online by clicking here.
Compliance with the law We will comply with the provisions of all applicable domestic and international laws and appropriate standards and principles.
Insider trading All Vodafone employees are expected to comply with all laws and regulations applicable to dealing with Vodafone shares.
In many jurisdictions there are laws that prohibit the trading of shares or manipulation of share prices based upon information you have by virtue of your employment or business relationships. It is your responsibility to comply with all applicable laws.
If you have access to inside information, you must not buy, sell or otherwise deal in Vodafone shares. You must not pass on any inside information to third parties, as not only will this be a breach of confidentiality, but you may also be committing an offence if they go on to trade in Vodafone shares. This applies even if you are no longer a Vodafone employee.
If you do have any doubts about whether you are entitled to deal in Vodafone shares, you should contact the Group Company Secretarial department.
More information For more information, see Vodafone’s policy on Owning Share